3EPA
United State*
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Respon**
DIRECTIVE NUMBER: 9840.2
TITLE: FINAL FY 86 SCAP DESTRUCTIONS
JUNE 27, 1985
JUNE 27, 1985
CWPE
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
0 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OS WER OS WER OS WER
VE DIRECTIVE DIRECTIVE Dl
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United States Environmental Protection Agency
41% .» _ - Washington. DC 20460
Ot PA OSWER Directive Initiation Reauest
Originator Information
Name of Contact Person
Michael Kilpatrick
Lead Office Q ^
U OERR 0 OWPE
D OSW Q AA.QSWER
Mail Code
WH-527
Interim Directive Numtx
9840.2
Telephone- Number
382-4819
Approved for Review
Signature of Office Directof ( J ,/
sjK. (L {Jt^
Date
• f-ti-fi
Title
Final FY 86 SCAP Instructions (W/O attachments)
Summary of Directive
This document further addresses planning of enforcement and fund-
financed activities in FY 86. Priorities, operating procedures
and targets are addressed.
Key words: SCAP, planning, targets, enforcement
activities, case budget, priorities
Type of Directive (Manual. Policy Directive. Announcement, etc./
Guidance
Status
D Draft
03 Final
LXJ New
LJ Revision
No Does It Supplement Previous Directives)? | | Yes
Does this Directive Supersede Previous Directives)? | | Yes
f "Yes" to Either Question. What Directive (number, title)
Review Plan
D AA-OSWER
D OERR
D OSW
D OUST
O OWPE
Q Regions
D OECM
D OGC
D OPPE
Other (Specify)
This Request Meets OSWER Directives System Format
Signature of Lead Office Dicctive's O
Date
Signature of OSWER Directives Officer
Date
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
V ASHINGTON. D.C. 20460
f 9840.2
JUN 2 7 :385
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Final FY 86 SCAP Instructions
FROM:
TO:
William N. Hedeman, Jr.,
Office of Emergency and Remedial ReVp
Gene A. Lucero, Director \Qj(MJU '*'
Office of Waste Programs Enforcement
Addressees
On May 9, 1985, we sent to you our passback on the preliminary
FY 86 Superfund Comprehensive Accomplishment Plan (SCAP). Over
the next several weeks we need to reexamine the projects and
activities that were proposed and determine what adjustments
should be made. This exercise will result in the final FY 86
SCAP which, among other things, establishes many of the Regional
Superfund SPMS targets.
The first step in this process will be the final revision of
the FY 85 SCAP. Between now and early July we will be visiting
or working with sach of you to discuss what will be accomplished
during the fourth quarter. You will then have time to reconsider
and make appropriate changes to the FY 86 SCAP. Division Directors
should submit a draft of this plan to Terry Ouverson (WH-548-D)
no later than July 24. We will review your submission and talk
with you about any alterations we think should be made. On
August 15 we wi 1 pass back a revised SCAP and will submit the
preliminary FY 86 SPMS targets to the
Systems Evaluation. Your final SCAP,
Administrator, is due on September 4,
allow us time to adjust
sistencies. A schedule
Office of Management and
signed by your Regional
1985. This will still
the SPMS targets if there are any incon-
outlining the SCAP and SPMS processes for
the remainder of .the year is attached (Attachment I).
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OSWER f 9840.2
-2-
Removal Instructions
In addition to confirming the FY 86 annual SCAP projections
for removal activity, please submit the number of anticipated
first quarter removal starts and completions broken down into
NPL and non-NPL categories. In early September, we will request
a list of names of the sites projected to be started or completed
in the first quarter and a projection of the number of removal
actions projected for the second, third and fourth quarters.
Reporting requirements and formats are unchanged from those
outlined in the FY 85 SCAP.
Remedial Instructions
Nationally, we plan to meet the number of Fund-financed
activities targeted in the Agency's FY 86 budget request: 130
RI/FS, 89 RDs and 56 RAs. The preliminary-SCAP was approved
with more dollars than are available under the assumption that
the final SCAP will reflect the results of FY 85, revised cost
estimates or funding schedules and other reordering of priorities.,
In the preliminary SCAP we asked you to take certain steps to
reduce the dollar budget of the plan while maintaining the current
number of targeted projects. These steps are reiterated below
and should be followed in preparing the final plan.
0 Obtain better estimates on large projects (over $10M).
Screen individual project budgets to ensure accuracy of cost
estimates.
0 Phase-fund more FY 86 new start and subsequent SCAP projects
to maintain the same number of new start RAs. Identify
smaller operable units for RA projects on the FY 86 SCAP.
Request only those funds needed for the next operable unit
occuring in FY 86.
0 Scrutinize same year RD/RA to ensure confidence in timeliness
and likelihood of obligation. If RA projects have a low
likelihood for obligation during the fiscal year, request
funding for the project in FY 87.
0 Examine the status of enforcement-lead projects which are
also scheduled for RD/RA funding on the FY 86 SCAP. Will
these projects need funding during the fiscal year? If so,
should the lead-status be changed, or should funding for the
project be moved "Below the Line" to make way for remedial
projects more certain of FY 86 funding. Funding should not
be requested for RD/RA at enforcement-lead sites unless
changed circumstances dictate changing the site classificatii
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OSWER f 9840.2
. -3-
The submission of the final FY 86 SCAP should use the
Preliminary FY86 SCAP as a baseline. Remaining FY 1985 fiscal
year activity must be carefully assessed to assure it will be
obligated in the current fiscal year, and if not, whether the
activity should appear on the FY86 SCAP. Since the number of
target projects on the Final FY86 SCAP cannot exceed those in
the approved Preliminary FY86 SCAP, sites with new activity
starts moved from FY85 must be accounted for within the FY86
targets. In addition, except for incremental funding required
to continue on-going activities, sites which appear on the final
fourth quarter FY85 SCAP may not be scheduled for the same activity
on the FY86 SCAP"
The fourth quarter FY85 SCAP will be sent to you by July 12,
1985. A copy of the remedial portion of the Preliminary FY86
SCAP is being transmitted to the Waste Management Division
Directors via electronic mail. This may then be copied on a
diskette in your Region which should reduce the amount of effort
required to update the SCAP.
The Final FY86 SCAP should be submitted as "Approved"
(target) and "Substitution" projects using the same format
depicted in the Preliminary SCAP. "Approved" projects represent
the highest priority projects which have the greatest likelihood
of requiring funding during the fiscal year. The number of
approved projects will be used to determine SPMS commitments.
"Substitution" projects are a pool of projects which are moving
toward the point of obligation and which may be substituted to
replace approved projects which are assumed by responsible parties,
experience schedule slippage, or are deferred because of revised
project priorities.
Please ensure that remedial completion targets are reviewed
and all activities which will come to a conclusion in FY 1986 and
beyond are identified on the plan. Completion progress will be
evaluated during the quarterly SCAP reviews. Completion targets
for RI/FS, RD and RA will include Fund-financed (program and
enforcement lead) and PRP activities. The July 24 submittal
should include Regional proposals for these targets.
The completion data will be taken from CERCLIS or (CMS for
PRP activity); only those sites recorded will be credited. Accurate
completion projections will have an impact on Region's resources
in FY 87 and subsequent years. Instructions for revising remedial
completion projections and projected outyear activities are
contained in Attachment II.
•
PA/SI Instructions
FY86 PA/SI targets have been reduced. The original
national Preliminary Assessment target was 5,500. This target
has been reduced by 27 percent to arrive at the new target of 4,000.
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OSWER # 9840.2
.4-
The original national Site Inspection target was 1,488. This
target has been reduced by 22 percent to arrive at the new target
of 1,160. Consequently, Regions should reduce their individual
PA and SI targets by the percentages shown above. Funding required
to conduct the program at these levels should be reflected in the
FY86 SCAP submission.
An objective in FY86 is to eliminate any overlap between
the FIT and the State Cooperative Agreement Program. The workload
distribution between the two programs should be reviewed and
coordinated to ensure the most effective use of resources
devoted to the program. In addition, existing FY85 State
Cooperative Agreements should be carefully reviewed to determine
what level of FY85 funding will remain for use in FY86. Upon
completing these steps, appropriate FY86 needs can be determined.
Please ensure that PA/SI funding requested for FY86 is only
the funding required to conduct the program during FY86. Regions
which have already negotiated FY86 funding levels with their
States may submit requests for funds to cover the negotiated
levels, but must clearly describe the amount and anticipated use
of the funds above that needed to support the reduced FY86 PA/SI
target level „
Sample Analysis Instructions
Instructions for updating your projections of demand for
sample analysis were sent to Waste Management Division Directors
in a May 15, 1985, memorandum from William N. Hedeman, Jr.,
(Attachment III ). Responses to that memorandum may be held in
abeyance until your work on the draft SCAP, due July 24, is
completed. Final sample analysis needs estimates should accompany
your draft SCAP submission on July 24.
Enforcement Instructions
To further streamline enforcement reporting, targets for
negotiations (all types) will be deleted. Projections for the .
sites that wilj[ enter negotiations will not be required.
However, quarterly reporting of negotiation initiations and .
completions will continue as part of the SCAP review process.
Each Region should revise the February Case Budget submittal
to reflect all anticipated extramural needs. As indicated in
previous correspondence, the FY86 case budgets will be managed by
the Regions with limited Headquarters involvement. Therefore, it
is Important that accurate budgets be developed so accurate
distribution of extramural funds can be made. Case budget
submittals should include needs for all OWPE contracts, lAGs and
buy-ins to any of the REM contracts. This should include amend-
ments to on-going work assignments which will be made after
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_ -JiWER f 9840.2
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October 1, 1985. We are retaining last year's format which
includes specifying activity and contract mechanisms for each
site (Attachment IV)". However, this year please list by name
the responsible party searches you plan to do.
Funding to States for oversight of PRP work will also be
Included in the case budget. As discussed in Gene Lucero's memo
of January 23, 1985, we will be funding State oversight of PRP
work at a limited number of State enforcement-lead sites. In
addition, some funds will be available for management assistance
to States at sites where PRPs are conducting work under an agree-
ment with EPA. Further guidance on the requirements and mechanisms
for providing such funding will be available later in the summer.
For this iteration of the case budget, please include all sites
at which your would like to fund such activities. Final decisions
on number of sites and level of funding will be made at a later
time. For oversight, the cost estimate should be similar to the
cost if EPA were to have a contractor do the oversight. For
management assistance, similar factors should be used as for
management assistance for Fund projects.
To assist you in making cost estimates, we have provided a
chart of average costs for various enforcement activities
(Attachment V). An area you should be particularly concerned
about this year is oversight of responsible party actions.
Although cost data is sketchy, please be sure to make your best
estimates of oversight needs, as oversight will no longer be
covered by the remedial portion of the SCAP and it could constitute
a large percentage of your overall extramural needs.
Once the revisons are received, OVIPE will develop Regional
budgets based on these submissions and the over-all enforcement
budget. It will then be the Regions's discretion to distribute
funds among active cases as needed. OWPE will provide monthly
accounting ledgers which track all contract obligations (Attachment
VI). Besides distribution of ledgers, OWPE involvement will be
very limited. OWPE will participate only in resolving conflicts
with the Department of Justice, distributing a contingency fund
and conducting a mid-year review where actual contract obligations
will be reviewed and compared to the case budget allocation.
Funds may be redistributed among Regions based on this review.
Attachments
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OSWER f 9840.2
-6-
Addressees:
Directors, Waste Management Division,
Regions I, IV, V, VII, VIII
Director, Office of Emergency and Remedial
Response, Region II
Directors, Air and Waste Management Division,
Regions II and VI
Di rector,
Region
Di rector,
Region
D1rector,
Di rectors,
Regions
Hazardous Waste Management Division,
III
Toxics and Waste Management Division,
IX
Hazardous Waste Division, Region X
Environmental Services Division,
I - X
cc: Superfund Branch Chiefs, Regions I - X
RCRA/CERCLA Branch Chiefs, Regions I - X
Regional Counsels, Regions I - X (w/o attachments)
Director, Resource Management Staff, OSWER (w/o attachments)
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OSWER # 9840.2
ATTACHMENT I
REVISED.FY 86 SCAP SCHEDULE
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OSVJER # 9840 .2
REVISED FY 86 SCAP SCHEDULE
Final FY 86 SCAP Instructions June 26, 1985
furnished to Regions
HQ finalizes SPMS measures and June 30, 1985
definitions with Regions
Fourth Quarter FY 85 SCAP July 12, 1985
furnished to Regions
First draft of FY 86 SCAP July 24, 1985
submitted to HQ by Regions
Passback to Regions on revised August 15, 1985
FY 86 SCAP
OSWER submits draft SPMS targets August 15, 1985
to OMSE
RA's submit final SCAP to AA.SWER September 4, 1985
AA.SWER signs final SCAP and September 20, 1985
furnishes to Regions
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'OSWER # 9840.3;
ATTACHMENT II
REMEDIAL COMPLETION ESTIMATES
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. . , r . „. T . OSWER # 9840.2
Remedial Completions Instructions
The attached report shows actual and projected RI/FS, RD and
RA starts and completions. FY 1985 and 1986 obligation amounts
are shown for reference only. Regions need not revise the
obligations shown on this report. This data will be updated by
Headquarters following completion of the final SCAP.
Please review the projected start and completion data and
make any changes by entering revised dates in the space provided
to the right of the existing dates. For planning purposes, as a
general rule RD's should be scheduled to begin in the quarter
following completion of an RI/FS1 and RA's in the quarter following
completion of an RD. Also, for sites having two or more entries
for the same activity, enter a brief decription of each entry.
(See attached sample)
Add new activities for existing sites by entering the
activity, lead, projected start and completion dates and, if
appropriate, activity descriptors at the botton of each site.
New sites should be added at the end of each Region's listing.
Our goal 1s to have RI/FS, RD and RA data for each site at
which an RI/FS is scheduled to begin through FY 1986. Legible
pen and Ink changes are acceptable for all revisions/additions.
RI/FS, RD and RA starts are defined as the year and quarter
of the first obligation for that activity as shown in the SCAP or
as projected for FY 1987 and beyond. The definition of RI/FS
completions is being changed from what was contained in the
preliminary SCAP to bring it into line with the Superfund Progress
Report and SPMS measures. The revised definition uses ROD signature
date instead of the date the draft Rod is completed as the RI/FS
completion date. Other completion definitions are unchanged
from what was shown in the instructions for the preliminary FY
1986 SCAP. Current definitions are as follows:
RI/FS - the quarter in which the ROD has been or will be
signed by the AA.SWER or the Regional Administator
if delegated.
RD - For Federal-lead, contract for implementation is
advertised for bids. For State-lead, design and
specifications approved by EPA.
RA - The operable unit 1s being monitored or operated to
ascertain the performance of the operable unit. If
the operable unit is the last operable unit, the
entire remedial action 1s 1n performance monitoring
prior to instituting deletion procedures. (In
essence, the date of final acceptance and beneficial
occupancy.)
Included with your mark-up, please provide us with the name and
phone number of the point of contact in your Region for this
Information. If you have any questions, please feel free to
~n Tarry Ouverson at (FTS) 475-9367.
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/17/1985
PACE
OPPICE OP EMERGENCY AND.
SUPERPUND MULTI-YE/!
RECU
AS OP
• ••*••***•****••****•***••*•*••**•*«•**************•*•*•*••• •!
EMEDIAL RESPONSE
PLANNING REPORT
2
• ST SITE NAME
I NJ LIPARI LANDPILL
PT 1985 PT
ACTIV PLANNED PY85 PLANN
ITT LO OBLIGATION ST>T1>»LJCA
LANDPI
633.000 A
0
r**************••*•**•••••«•*•*•*•*«*•*************«
REVIS PLAN REVIS
TR/QR TR/QR YR/QR DURA
1C OBLIC COMP CONP TION
OS NY LOVE CANAL
102ND/TRBET
ADMIN/ BLDG.
AIR
CONTAINMENT
CONTAINMENT
CONTAINMENT,
CONT\£NM
CREEKS
CREEKS
HABITAT
HABITAT
PEER
PERIMETER
PERIMETER
S 4 C
SEWERS
SEWERS.
82/4
83/4
83/4
S. 0 84/3
X 0 85/4
SOO>fiOO APR 86/2
L000
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OSWER # 9840.2
ATTACHMENT IV
FY 1985 ENFORCEMENT PROGRAM SUPPORT
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OSWFR # 9840.2
SAMPLE REPORTING FORMAT
FY 85 ENFORCEMENT PROGRAM SUPPORT
REGION
I. Site Classification/Responsible Party Searches
_JL II III IV
Quarterly RPS Targets - 12 17 5 8
Total S (K) 12 17 5 8
Total Regional Budget Target - $12,000 x 42 = $50,400
First Two Quarter's Obligation - $34,800
II. Case Development- *
Site/State
XXX Recycling, RE
Slime Pits, SL
Waste Harbor, PS
AA Preservers, TA
Dregs Dump, OL
Contract
Mechanism
TES
TES
TES
TES
uses
TES
COE
uses
OTHER
TES
ment Target
Expected Obligation
Activity
TECH RD
REC COMP
EXPERT
EXPERT
S ENV
FS
CM
EXPERT
EXPERT
EA
s -
I II
9
11
25
20
45
75
56 129
III
60
10
20
90
( SK :
.IV
20
20
Total Regional Budget Target - $ 295,000
First 2 Quarters Obligation - $ 185,000
* give estimates for all active cases, not just new cases on the SCAP
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OSWER # 9840.2
ATTACHMENT V
ENFORCEMENT TASK COSTS SUMMARY
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OSWER # 9840.2
FY 85
Enforcement Task Costs
Summary
Activity Cost($)
Responsible Party Search 11,898
Title Search 4,750
Financial Assessment 15,522
Records Compilation 11,888
Endangerment Assessment 39,754
Remedial Investigation 149,800
RI/FS Workplan - 29,790
Hydrogeologic Studies 171,450
Feasibility Studies 111,635
Focused-Feasibility Studies 25,790
Sample - Collection & Analysis 6,768
Technical Review of Documents 11,198
Expert Witnesses/Consultants 23,360
Comments
50% include TS & FA
only non-routine done
separately from the RPS
non-NPL sites
per expert;includes fact
witnesses
Oversight
20-150,000
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OSWER # 9840.2
ATTACHMENT VI
ENFORCEMENT CONTRACT STATUS SHEET
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OSWER ft 9840.2
EXAMPLE
CONTRACT STATUS SHEET
REGION 2
I. Case Budget Sites
SITE
XYZ
ACTIVITY
EFFECTIVE DATE
CONTRACT BUDGET ACTUAL DIFFEREN
TECH REVIEW DOC TES I 15 K 20 K - 5 K
PITS LDFLL RESP PARTY SEARCH TES II 10 K 8 K + 2 K
SUB-TOTAL
25 K
28 K
- 3 K
II. Non-Case Budget Sites
SITE
AAA RECYCLERS
SLIME LDFLL
SUB-TOTAL '•
TOTAL
ACTIVITY CONTRACT
OVERSIGHT COE
EXPERT TES II
BUDGET
0
0
0
25
K
K
K
K
ACTUAL
50
20
70
98
K
K
K
K
DIFFERE
- 50
- 20
- 70
- 73
K
K
K
K
III. Remaining Budget Amount
Case Budget - Actual Obligations as of date =
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